IN RE ZETA GLOBAL HOLDINGS CORP. STOCKHOLDER DERIVATIVE LITIGATION

Filing 15

ORDER granting #14 Motion to Adjourn Conference. Application GRANTED. The initial pretrial conference scheduled for February 4, 2025, and the associated January 30, 2025 deadline to submit a joint case management plan, are ADJOURNED sine die in light of the forthcoming stay request. SO ORDERED. (Signed by Judge Dale E. Ho on 1/28/2025) (jjc)

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January 28, 2025 VIA ECF The Honorable Dale E. Ho United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, New York 10007 Application GRANTED. The initial pretrial conference scheduled for February 4, 2025, and the associated January 30, 2025 deadline to submit a joint case management plan, are ADJOURNED sine die in light of the forthcoming stay request. SO ORDERED. Dale E. Ho United States District Judge Dated: January 28, 2025 New York, New York Re: In re Zeta Global Holdings Corp. Stockholder Derivative Litigation, Master File No.: 1:24-cv-09450-DEH-SDA - Request for Adjournment of Conference (This Document Relates to All Actions) Dear Judge Ho: We represent Defendants David A. Steinberg, Christopher Greiner, John Sculley, Imran Khan, William Royan, Jené Elzie, William Landman, Robert Niehaus, and Jeanine Silberblatt (collectively, the “Individual Defendants”), and nominal Defendant Zeta Global Holdings Corp. (“Zeta,” and collectively with the Individual Defendants, “Defendants”) in the above-captioned action and write, jointly with Plaintiffs Ashraf Mostafa and Jae Hyung Jung (“Plaintiffs”), pursuant to Your Honor’s Individual Rule 2.e. regarding scheduling.1 The parties respectfully ask the Court to adjourn the initial pretrial conference scheduled for February 4, 2025, and the associated January 30, 2025 deadline to submit a joint case management plan sine die. The parties are currently negotiating a stipulation that would request the Court to stay the Consolidated Derivative Action in light of the related Securities Class Action. Accordingly, to conserve the Court’s time and resources, the parties respectfully ask the Court to adjourn the January 30, 2025 deadline to file a joint letter and proposed civil case management plan, as well as the initial pre-trial conference scheduled for February 4, 2025, to allow the parties to finalize their request that the case be stayed, and to submit it for the Court’s consideration and approval. In addition, pursuant to Your Honor’s Individual Rule 2.e.v., the parties will propose agreed-upon alternative conference dates in the event that the parties fail to reach an agreement, or if the Court declines to stay the Consolidated Derivative Action. This is the first time that the parties have requested an adjournment of the initial pretrial conference date. We appreciate the Court’s consideration of this matter. 1 On January 2, 2025, the Court consolidated the Mostafa Action and the Jung Action because they contain substantially similar factual and legal contentions (the “Consolidated Derivative Action”), see 1:24-cv-09450-DEH, ECF No. 12; 1:24-cv-09907-DEH, ECF No. 9. Both actions are related to Davoodi v. Zeta Global Holdings Corp., 1:24-cv-08961-DEH-SDA (the “Securities Class Action”). Respectfully submitted, /s/ Timothy Brown /s/ Colleen C. Smith THE BROWN LAW FIRM, P.C. Timothy Brown2 767 Third Avenue, Suite 2501 New York, NY 10017 Tel: (516) 922-5427 Fax: (516) 344-6204 Email: tbrown@thebrownlawfirm.net jcoyle@thebrownlawfirm.net Colleen C. Smith (admitted pro hac vice) LATHAM & WATKINS LLP 12670 High Bluff Drive San Diego, CA 92130 Telephone: (858) 523-5400 Email: colleen.smith@lw.com Attorneys for Plaintiff Mostafa GAINEY McKENNA & EGLESTON /s/ Thomas J. McKenna Thomas J. McKenna Gregory M. Egleston Christopher M. Brain 260 Madison Avenue, 22nd Floor New York, NY 10016 Tel: (212) 983-1300 Fax: (212) 983-0383 Email: tjmckenna@gme-law.com gegleston@gme-law.com cbrain@gme-law.com Megan A. Behrman Thomas J. Giblin LATHAM & WATKINS LLP 1271 Avenue of the Americas New York, NY 10020 Telephone: (212) 906-1200 Email: megan.behrman@lw.com thomas.giblin@lw.com Attorneys for Defendants Attorneys for Plaintiff Jung cc: 2 All Counsel of Record (via ECF) Defendants use electronic signatures with consent in accordance with Rule 8.5(b) of the Court’s ECF Rules and Instructions.

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